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The GOP, by and through Nixon Peabody Attorney Gordon MacDonald, actually stated to this Honorable Court in apparent violation of Rule 3.3 Candor to the Tribunal, that Plaintiff has not shown where the GOP NH or Nashua had him ordered out of any event or building.

Similarly the Nashua Police Defendants, by and through Brian Cullen, have claimed that they were kind, gentle and not overreaching.

Both of these claims are clearly false....

as Plaintiff has shown on prior occasion that NH Police at the Nashua John McCain VFW rally harassed him even as he followed police orders to remain on the sidewalk as white people were standing yet closer than Plaintiff to a backing car with a huge belt drive problem.

In this video, which was unavailable by excusable neglect -- i.e. Plaintiff's housemate had misplaced this video card -- the Court can clearly see that Nashua PD threw Plaintiff out of the direct event and out of the entire building, acting on direct orders from GOP Communications Chair Di Lothrop.

That goes to the First Amendment and racial claims, as the Police presence and actions did not allow Plaintiff the right to stay and get a bite to eat in a place of public accommodation.

"Right, this is a place of public accommodation, I can chill here, get a sandwich," Plaintiff said.

Yet the Nashua PD never changed their position.

May it please the Court to know that any reasonable person would not have thought that he or she could remain on the premises because the Nashua Police, by and through white Officer Hargreaves, refused to retreat or back off from their position. Recall that white Officer Hargreaves saw a white GOP operative Karen Thoman strike Plaintiff's camera, said nothing to her and admonished Plaintiff the he was not to "touch anyone else."

May it please the Court to know further that while Plaintiff was forced to work as a waiter for a while because of the bogus racially-motivated First Amendment attack by Kelly Ayotte and fired Jaffrey Police Chief Martin Dunn, he went on to resume a career in wireless communications, working as a zoning manager for the same client represented by Jennifer Parent and McLane, Graf. Plaintiff is not here looking for a handout, he is looking for honesty, integrity and Justice.

As Plaintiff has misplaced this video card he apologizes for the late entry, but he notes further that this case -- contrary to mis-cited law set forth by Defendants on prior occasion -- is at a Motion to Dismiss stage and any and all relevant information is to be considered.

Plaintiff hereby assents to a response from Defendants.

This situation is best viewed in light of the colloquy between Monier and Plaintiff that is reminiscent of a 1960’s style cafeteria sit-in at Woolworth’s. Once again the Defendants went beyond that which was necessary there as well, with Monier threatening to arrest Plaintiff as he stood on a public sidewalk, a fact that Defendants cannot dispute. And going well beyond a Motion to Dismiss, a Jury is clearly entitled to determine whether racial animus caused the Defendants to go beyond what was necessary to keep Plaintiff out of the actual event:

“You have been disinvited,”

“Because why”

“you haven’t paid….”

“What, my money’s not good enough

“That’s right.”

“I don’t want your money” echoed another white man in hateful pitch.

Between the two of them there wasn’t an ounce of kindness to spare, and Plaintiff was indeed scared of them when they put their hands on him, and that’s called a Common Law Assault. One can see it and feel it in the air behind his scowl. Palpable.

In addition to this Supplemental filing that I will finish and file for Leave on today, I am contemplating the filing of a Rule 11 Motion regarding any and all statements that the GOP did not order me out of any building or event. In fact, I am fairly certain I will do that, and I will send you and the entire Free World a copy of the proposed Rule 11 filing by tomorrow, Sunday, 23 January 2011.

In the alternative you can retract those statements and everything will be fine.

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I shoot Courtroom video like no one else in the Country. I'm an inquisitive guy with a camera, a law degree, AAG experience, journalism experience, trial experience, managerial mortgage, title insurance and property experience and an open mind.